The European Lotteries
EL
The European Lotteries (EL) is the European umbrella organisation of lotteries operating games of chance for the public benefit.
ID: 97609783845-15
Lobbying Activity
Response to Protection of Minors Guidelines
27 Sept 2024
Please see attached submission by The European Lotteries Association.
Read full responseMeeting with Antonella Sberna (Member of the European Parliament) and Sisal Italia s.p.a.
17 Sept 2024 · Gambling policies and legislation, Internal market harmonization, consumer protection and responsible gambling.
Meeting with Aldo Patriciello (Member of the European Parliament)
17 Sept 2024 · first general meeting
Response to Virtual worlds, such as metaverse
2 May 2023
The European Lotteries Association (EL) appreciates the opportunity to share its views on the upcoming initiative of the European Commission on the metaverse. EL strongly believes that the metaverse should not be a space exempt from the rule of law or beyond any jurisdiction. It is a virtual space including augmented reality where the rules relating to the Internet and online services should apply. The principle of technology neutrality should be observed and the objective pursued by the legislators when developing the Digital Services Act should prevail and be completed as follows: what is illegal offline should be illegal online as well as in the metaverse. This is particularly the case for gambling offerings and advertising. This sector remains subject to the relevant national legislation, whether it provides for a license or an exclusive rights regime, or even where needed, according to the national situation, for a ban of the most harmful forms gambling segments. Thereupon, metaverse must not be a no-rights zone for the players. Gambling and betting operators cannot be exempt from a regulation aiming at protecting consumers, vulnerable persons and minors, simply because they offer those services in a new technological environment. In the same way, should EL members chose to operate in the metaverse, they would do so while implementing their responsible gambling policy, measures and protective tools. Customers safety will always be the prime concern of the lotteries, along with their contribution to society allocating part of their revenues to local good causes. In addition, by allowing Member States to adopt stricter measures, the EU framework pertaining to anti-money laundering and anti-terrorism financing gives to the national and local relevant authorities the possibility to subject the providers of crypto assets and NFT giving rise to speculation to the existing obligations in this field. Given the corresponding risks entailed in this specific sector, the use of crypto currencies can also be banned in the gambling sector, as it is currently the case in some jurisdictions. *** About the European State Lotteries and Toto Association (EL) EL is the European umbrella organization of national lotteries operating games of chance for the public benefit in 44 European countries with a total of 76 members, including all EU Member States. It is the largest and most representative lottery and gambling sectors organization in Europe whose members only operate in those jurisdictions in which they are licensed and where they comply with the legal requirements (e.g. anti-money laundering, responsible gaming policies, etc.). EL stands for the sound and sustainable gaming model for the benefit of society based on the values of subsidiarity, precaution, solidarity and integrity. In 2021, EL members secured 20 billion for society and directly supported valuable projects related to sport, cultural heritage, art, individuals with disabilities/disadvantages, education, science and many other areas. More info about EL is available at: https://www.european-lotteries.org/about-el
Read full responseResponse to EU Supranational Risk Assessment on money laundering and terrorist financing
27 Mar 2017
The European Lotteries Association (EL) is the umbrella organisation of national lotteries operating games of chance for the public benefit (www.european-lotteries.org). Our comments pertain to the elements on gambling in the AMLD4. The European Lotteries urges the Commission to not make a unilateral recommendation with regard to the transposition of the articles pertaining to gambling in the Supranational Risk Assessment (SNRA).
According to the case law of the European Court of Justice, it is appropriate to bear in mind the specific nature of legislation on betting and gambling, which is one of the areas in which there are significant moral, religious and cultural differences between the Member States. It is for each Member State to determine in those areas, in accordance with its own scale of values, what is required in order to ensure that the interests in question i.e. consumer protection and public order, are protected. This means that the principle of subsidiarity prevails.
Accordingly, national authorities enjoy a wide measure of discretion when determining what is required in order to ensure consumer protection and the preservation of order in society. Some Member States may consider that lottery games as operated by the state lottery represent a low risk notably due to factors such as a low payout ratio, the direct supervision of the public authorities, the monopoly, the national territory-bound offering, the small amounts played and the limited choice of payment methods. Some other Member States may consider, given the particular risks entailed in terms of resale of winning tickets or retailers’ collusion, that specific anti-money laundering measures should be set up in the lottery game sector.
The regulatory choice to exclude or not lotteries for their lottery games and, if not, to which kind of measures they are to be subject can differ from Member State to Member State, as foreseen by the Directive.
Accordingly, the EL feel strongly that the Supranational Risk Assessment needs to leave the room for Member States to exercise subsidiarity fully, while staying in line with the framework of the options set out by the Directive. The freedom of national authorities to decide how they intend to transpose the provisions of the Directive should not be put into question ex ante, the supranational risk assessment’s aim being to allow them to make an informed choice in this regard.
To this regard, we point out that following it adoption by the Member States and the European Parliament, the AMLD4 presents four different categories of transposition possibilities to national law with regard to gambling as a sector or with regard to specific gambling products:
1) Application of the due diligence controls upon collection of winning when carrying out transactions amounting to EUR 2 000 or more, whether the transaction is carried out in a single operation or in several operations which appear to be linked;
2) Application upon the wagering of a stake amounting to EUR 2 000 or more, whether the transaction is carried out in a single operation or a single operation or in several operations which appear to be linked;
3) Application of due diligence controls upon both wagering of a stake and the collection of winnings amounting to EUR 2 000 or more, whether the transaction is carried out in a single operation or in several operations which appear to be linked;
4) The exemption – fully or in part – providers of certain gambling services (with the exception of casinos and following an appropriate risk assessment) from national provisions transposing the provisions of this Directive on the basis of the proven low risk posed by the nature and; where appropriate, the scale of operations of such services.
The final guidance document should take into account these options contained in the Directive as adopted by the legislators, European Parliament and Council.
Read full responseMeeting with Szabolcs Horvath (Cabinet of Commissioner Tibor Navracsics)
22 Apr 2015 · Presentation of The European Lotteries organisation, fight against match-fixing, European Week of Sport